1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other order enquiries.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

2. Hosting and Content Delivery Networks (CDN)

We are hosting the content of our website at the following provider:

Strato

The provider is Strato AG, Otto-Ostrowski-Straße 7, 10249 Berlin (hereinafter referred to as “Strato”). When you visit our website, Strato records various logfiles, including your IP addresses.

For more information, please consult the Strato Data Privacy Policy: https://www.strato.de/datenschutz/.

Strato is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in a depiction of our website that is as reliable as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Google Cloud CDN

We use the Google Cloud CDN content delivery network. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google offers a globally distributed content delivery network. Technically, the transfer of information between your browser and our website is routed through the Google network. This enables us to increase the global accessibility and performance of our website.

The use of Google Cloud CDN is based on our legitimate interest in the most error-free and secure provision of our website (Art. 6(1)(f) GDPR).

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://cloud.google.com/terms/eu-model-contract-clause.

You can find more information about Google Cloud CDN here: https://cloud.google.com/cdn/docs/overview?hl=en.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

Partnerschaftsgesellschaft Penner + Partner mbB
Humboldtstraße 10
40237 Düsseldorf

Phone: +49 (0) 211 680400
E-mail: info@pennerundpartner.de

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Designation of a data protection officer

We have appointed a data protection officer.

bits + bytes it-solutions GmbH & Co. KG
Krombacher Straße 24
57223 Kreuztal

Phone: +49 (0) 700 20 30 10 30
E-mail: datenschutz@bits-bytes.de

Recipients of personal data

In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

• In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
• If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
• If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
• If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

Which cookies and services are used on this website can be found in this privacy policy.

Consent with Borlabs Cookie

Our website uses the Borlabs consent technology to obtain your consent to the storage of certain cookies in your browser or for the use of certain technologies and for their data privacy protection compliant documentation. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg, Germany (hereinafter referred to as Borlabs).

Whenever you visit our website, a Borlabs cookie will be stored in your browser, which archives any declarations or revocations of consent you have entered. These data are not shared with the provider of the Borlabs technology.

The recorded data shall remain archived until you ask us to eradicate them, delete the Borlabs cookie on your own or the purpose of storing the data no longer exists. This shall be without prejudice to any retention obligations mandated by law. To review the details of Borlabs’ data processing policies, please visit https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/

We use the Borlabs cookie consent technology to obtain the declarations of consent mandated by law for the use of cookies. The legal basis for the use of such cookies is Art. 6(1)(c) GDPR.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

• The type and version of browser used
• The used operating system
• Referrer URL
• The hostname of the accessing computer
• The time of the server inquiry
• The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Social media

LinkedIn

This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Any time you access a page of this website that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn.

The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/help/linkedin/answer/a1343190/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=de.

For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5448.

6. Plug-ins and Tools

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyzes the behavior of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.

reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.

Data are stored and analyzed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and Terms Of Use under the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

7. Custom Services

Handling applicant data

We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 BDSG according to German Law (Negotiation of an Employment Relationship), Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.

Privacy Notice for Clients and Prospective Clients
of the partnership Penner + Partner mbB
in accordance with Articles 13 or 14 of the GDPR

With this privacy notice, we inform our clients (customers) and prospective clients, in accordance with the General Data Protection Regulation (GDPR) applicable as of May 25, 2018, about the processing of personal data by us and about the corresponding rights of data subjects.

Who is responsible for data processing?

The controller within the meaning of data protection law is

Partnerschaftsgesellschaft Penner + Partner mbB
Humboldtstraße 10
40237 Düsseldorf

You can find further information about our firm, details of the persons authorized to represent it, and additional contact options in the legal notice on our website at https://www.pennerundpartner.de/impressum/

Contact details of the Data Protection Officer:

Our Data Protection Officer

We have appointed a Data Protection Officer in our company. You can reach them using the following contact details:

bits + bytes it-solutions GmbH & Co. KG
– Data Protection Officer –
Krombacher Str. 24
57223 Kreuztal
Email: datenschutz@bits-bytes.de

The Data Protection Officer of the firm can be contacted at the above firm address and at datenschutz@bits-bytes.de. Please mark postal correspondence to the Data Protection Officer with the addition “Data Protection – personal/confidential”.

What data do we process about you? And for what purposes?

We process the following personal data, which we generally collect directly from the data subject (e.g., collection of data for the specific handling of the mandate) or data which we do not collect directly from the data subject (data of employees of our clients for payroll accounting) or data of children of our clients within the scope of necessary tax purposes (e.g., mandatory information about children in income tax returns):

• First and last name, form of address, if applicable title
• Postal address(es)
• Telephone number(s)
• If applicable, fax number(s)
• Email address(es)
• All information required for the proper execution of the mandate

If the scope of application of the German Money Laundering Act applies, we are obliged to collect and process further information, Section 2 (1) No. 10 GwG. This includes, among other things, information about your identity, beneficial owners, the purpose and nature of the business relationship and the transactions carried out, as well as the money laundering risk. For natural persons, in order to fulfill our obligations under the Money Laundering Act pursuant to Section 8 (2) sentence 1 GwG, we additionally create a copy of an official identification document of the client. For legal entities, the information required under the Money Laundering Act regarding beneficial owners within the meaning of Section 3 GwG is also collected.

We process personal data for the purposes of:

• Execution and handling of the mandate, including correspondence
• Fulfillment of our contractual and statutory obligations as tax advisors
• Processing within the framework of mutual claims arising from the tax advisory contract (e.g., invoicing, claims for services, remuneration, liability, etc.)

On what legal basis is this processing carried out?

The legal bases for the processing of personal data in our firm are:
Art. 6 (1) subparagraph 1 (b) GDPR for the performance of the mandate contract
Art. 6 (1) subparagraph 1 (c) GDPR for compliance with legal obligations to which we are subject as tax advisors
Art. 6 (1) subparagraph 1 (f) GDPR, insofar as processing is necessary to safeguard legitimate interests of ours or a third party; in particular, maintaining an ongoing business relationship with our clients constitutes a legitimate interest
Art. 6 (1) subparagraph 1 (a) GDPR, insofar as you have given your consent to the processing of your personal data for specific purposes

To which recipients are the data disclosed?

We disclose your data to third parties within the scope of fulfilling our obligations under the underlying contracts pursuant to Art. 6 (1) sentence 1 (b) GDPR, insofar as this is necessary for handling the mandate. This includes, in particular, disclosure to opposing parties and their representatives, as well as courts and other public authorities for the purposes of correspondence and for asserting and defending your rights, and to banks for payment processing. Furthermore, we use external technical service providers as processors pursuant to Art. 28 GDPR, who are carefully selected and monitored by us. Disclosure may also occur on the basis of legal provisions, for example for reporting suspicious activities pursuant to Section 43 GwG to the competent authority. The legal basis for such disclosure is Art. 6 (1) sentence 1 (c) GDPR in conjunction with Section 43 GwG.

We disclose personal data within the scope of the mandate to the following possible recipients:

• • Tax authorities and courts
  • Auditors, lawyers, notaries
  • Social security institutions
  • Bundesanzeiger Verlag GmbH
  • Banks, credit institutions, insurance companies, and professional associations
  • Processors (e.g., data centers, IT service providers, printing service providers, disposal companies, etc.), whose services we only use insofar as they are obligated to maintain our professional confidentiality pursuant to Section 203 (3) of the German Criminal Code
  • Depending on the assignment, additional recipients coordinated with you

Is data transferred to third countries?

Data is transferred to third countries (countries outside the European Economic Area – EEA) only if this is necessary for the performance of the mandate contract (e.g., payment orders), if you have given your consent, or if this is otherwise legally permitted. In such cases, we take measures to ensure the protection of your data, for example through contractual arrangements. We only transfer data to recipients who ensure the protection of your data in accordance with the provisions of the GDPR for transfers to third countries (Articles 44 to 49 GDPR).

How long is the data stored?

Your personal data will be processed and stored for as long and to the extent necessary for the purposes stated in this notice. After these purposes have been fulfilled, the data will generally be deleted. However, deletion will not take place if further processing for a limited period is necessary to comply with statutory retention obligations or for documentation and evidence purposes within the framework of limitation periods. In connection with the aforementioned retention periods, paper files will be destroyed in compliance with data protection regulations and data will be deleted from IT systems.

What rights do you have as a data subject?

You have the following rights as a “data subject” whose data we process:

• Right of access pursuant to Art. 15 GDPR
• Right to rectification pursuant to Art. 16 GDPR
• Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR
• Right to restriction of processing pursuant to Art. 18 GDPR
• Right to data portability in a structured, commonly used, and machine-readable format pursuant to Art. 20 GDPR

If we process your personal data for specific purposes on the basis of your consent, you have the right pursuant to Art. 7 (3) GDPR to withdraw your consent at any time. Upon receipt of your withdrawal, we will cease processing the data for the purposes for which you gave consent. The lawfulness of processing prior to the withdrawal remains unaffected.

Right to object: If we process your personal data to safeguard legitimate interests within the meaning of Art. 6 (1) subparagraph 1 (f) GDPR, you have the right pursuant to Art. 21 (1) GDPR to object to such processing on grounds relating to your particular situation. You may object to processing for direct marketing purposes at any time without giving reasons pursuant to Art. 21 (2) GDPR. To exercise your right to object, an informal notification to us (e.g., by email) specifying the processing to which you object is sufficient.

Right to lodge a complaint
If you believe that the processing of your personal data violates the GDPR, you have the right to lodge a complaint pursuant to Art. 77 (1) GDPR with a supervisory authority for data protection (generally the state commissioner for data protection and freedom of information). The complaint may in particular be lodged with the supervisory authority responsible at your place of habitual residence, place of work, or the place of the alleged infringement. At the registered office of our firm, the following supervisory authority is responsible: https://www.ldi.nrw.de/. A list of data protection officers and their contact details can be found at: https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html

Does automated decision-making take place?
No technologies are used within the scope of contract performance/service provision or contract initiation that enable profiling pursuant to Art. 4 No. 4 GDPR or automated decision-making pursuant to Art. 22 GDPR.

These notices reflect the status as of March 12, 2026. We reserve the right to adapt our privacy notice to changes in regulations or case law.

Privacy Notice for Applicants

We are pleased that you are interested in us and have applied or are applying for a position in our company. Below, we would like to provide you with information on the processing of your personal data in connection with your application.

Who is responsible for data processing?

The controller within the meaning of data protection law is

Partnerschaftsgesellschaft Penner + Partner mbB
Humboldtstraße 10
40237 Düsseldorf

You can find further information about our company, details of the persons authorized to represent it, and additional contact options in the legal notice on our website:
https://pennerundpartner.de/en/impressum/

What data do we process? And for what purposes?

We process the data that you have sent to us in connection with your application in order to assess your suitability for the position (or, if applicable, other open positions in our company) and to carry out the application process.
If we consider it necessary for filling the position, it cannot be ruled out that we will also collect personal data about you from third parties. This may include, for example, internet research or research in the area of “social media” (e.g., LinkedIn, XING). In this respect, we already refer to the supplementary information at the end. Any additional information required under Art. 14 GDPR in such cases will be provided to you separately, if necessary.

On what legal basis is this processing carried out?

The legal basis for processing your personal data in this application procedure is primarily Art. 6 (1) lit. b) GDPR.
Accordingly, the processing of data is permitted if it is necessary in connection with the decision on the establishment of an employment relationship.
Should the data be required after completion of the application process for legal enforcement, processing may be carried out on the basis of the requirements of Art. 6 GDPR, in particular for the protection of legitimate interests pursuant to Art. 6 (1) lit. f) GDPR. Our interest in this case lies in the assertion or defense of claims.
If special categories of personal data within the meaning of Art. 9 GDPR are processed (e.g., health data), the legal basis is Section 26 (3) BDSG or Art. 9 (2) lit. b) GDPR in conjunction with Art. 6 (1) lit. b) GDPR.

How long is the data stored?

Data of applicants will be deleted after 6 months in the event of rejection.
In the event that you have consented to further storage of your personal data, we will include your data in our applicant pool. There, the data will be deleted after two years.
If you are offered a position during the application process, your data will be transferred from the applicant data system to our personnel information system.

To which recipients are the data disclosed?

We use a specialized software provider for the application process. This provider acts as a service provider for us and may, in connection with the maintenance and servicing of the systems, also gain knowledge of your personal data.
We have concluded a data processing agreement with this provider to ensure that data processing is carried out in a lawful manner.
After receipt of your application, your applicant data will be reviewed by the HR department. Suitable applications will then be forwarded internally to the department managers responsible for the respective open position. The further procedure will then be coordinated. Within the company, only those persons have access to your data who require it for the proper conduct of our application process.

Where are the data processed?

The data are processed exclusively in data centers located in the Federal Republic of Germany.

Your rights as a “data subject”

You have the right to obtain information about the personal data we process about you.

In the case of a request for information that is not made in writing, we ask for your understanding that we may require proof from you that you are the person you claim to be.
Furthermore, you have the right to rectification or erasure or to restriction of processing, insofar as you are legally entitled to do so.
You also have a right to object to processing within the scope of the legal provisions. The same applies to the right to data portability.

Our Data Protection Officer

We have appointed a Data Protection Officer in our company. You can reach them using the following contact details:

bits + bytes GmbH & Co. KG
– Data Protection Officer –
Krombacher Str. 24
57223 Kreuztal
Email: datenschutz@bits-bytes.de

Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority regarding our processing of your personal data. A list of supervisory authorities with addresses can be found, for example, at:
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

Supplementary information on the processing of personal data not collected from the data subject (Art. 14 GDPR)

In the event that we process personal data about you in the course of the application process that we have not obtained directly from you, the following additional information applies:
The categories of data we may process in this context include information about you that is publicly accessible on the internet or can be researched via “social media” platforms (e.g., LinkedIn, XING). It may also include data about previous employment relationships. The legal basis for this data processing is Art. 6 (1) lit. f) GDPR, whereby our interest lies in identifying the most suitable candidates for the respective positions.
In the event that we process personal data about you that we have not collected from you, we will inform you separately about the source of the personal data, unless you already have this information. For further information required under Art. 14 GDPR, please refer to the information provided in this privacy notice.
V1.6 12/03/2026

Terms of Use and Privacy Notice for the Use of the WLAN
at Partnerschaftsgesellschaft Penner + Partner mbB

Terms of Use:

1. Subject Matter and Scope of these Terms of Use
These Terms of Use govern your and our rights and obligations in connection with the use of our WLAN access.

2. Our Services

1. We provide you with access to the Internet in the form of a WLAN access (“hotspot”) for free use.
2. The provision of the hotspot depends on our respective technical and operational capabilities. There is no entitlement to a functional hotspot or to a specific geographical coverage of the hotspot.
3. We also do not guarantee that the hotspot can be used without interruptions or disruptions. Nor can we guarantee transmission speeds.
4.  We reserve the right to change, restrict, or discontinue access to the hotspot without prior notice in the event of necessary technical repair and maintenance work.
5.  There is no entitlement to the use of certain services via the hotspot. In particular, port blocking may be implemented. As a rule, web browsing and the sending and receiving of emails are permitted.

3. Access and Use

1. A prerequisite for use is that you register for the use of the hotspot and/or accept these Terms of Use at the beginning of use. This usually takes place when selecting the hotspot as a WLAN network on your device via a registration form or a welcome page.
2.  There is no entitlement to use the hotspot. We are free to restrict or discontinue access to the hotspot at any time without stating reasons.
3.  The current version of these Terms of Use applies, which will be made available to you when logging in to the hotspot.

4. Access Data

1. If you have provided login data (such as username, password, email, etc.) as part of a registration, you must keep this data confidential and not make it accessible to unauthorized third parties.
2. If you have received registration data, you must ensure that access to and use of the hotspot using your user data is carried out exclusively by you as the user. If there are indications that unauthorized third parties have obtained or will obtain knowledge of your access data, you must inform us immediately.
3. As a user, you are liable for any use and/or other activity carried out under your access data in accordance with statutory provisions.

5. Your Obligations as a User

1. You are obliged to provide truthful information about yourself when using the service.
2. You are obliged to comply with applicable laws when using our hotspot.
3. Further obligations arising from other provisions of these Terms of Use remain unaffected.

6. Prices
The service is provided free of charge.

7. Availability of Services
As our services are provided free of charge, you have no entitlement to use the hotspot. However, we strive to ensure the most uninterrupted usability possible.

8. Prohibited Activities
As a user, you are prohibited from any activities when using the hotspot that violate applicable law, infringe third-party rights, or violate youth protection regulations. In particular, the following activities are prohibited:

• posting, distributing, offering, or advertising pornographic content, content/services/products that violate youth protection laws, data protection laws, or other laws, and/or fraudulent content;
• publishing or making available content that insults or defames other participants or third parties;
• using, providing, or distributing content, services, and/or products that are legally protected or encumbered with third-party rights (e.g., copyrights) without being expressly authorized to do so;
• making copyrighted works publicly accessible or otherwise infringing copyright laws, particularly when using so-called “file-sharing” or peer-to-peer services.

Furthermore, regardless of any legal violation, the following activities are also prohibited when posting your own content on the service provider’s website or when communicating with other users (e.g., via personal messages or participation in forums):

• transferring unusually large volumes of data, particularly on a sustained basis;
• hosting a web server or other servers via the hotspot;
• changing the preset DNS servers in the hotspot’s network settings;
• sending junk or spam emails and chain letters;
• distributing viruses, trojans, or other harmful files;
• distributing or communicating offensive, obscene, sexually explicit, or defamatory content, or content that promotes or supports racism, fanaticism, hatred, physical violence, or illegal acts (explicitly or implicitly);
• requesting other users or third parties to disclose passwords or personal data for commercial or unlawful purposes.

Any activity that is likely to impair the smooth operation of our hotspot is also prohibited, particularly actions that place an excessive load on our systems.

9. Blocking of Access
We may temporarily or permanently block your access to the hotspot if there are concrete indications that you are violating or have violated these Terms of Use and/or applicable law, or if we have another legitimate interest in blocking access.

10. Indemnification

1. As a user, you are responsible for all actions you take in connection with the use of the Internet via our hotspot.
2. You shall indemnify us upon first request against all claims asserted by third parties against us due to a violation by the user of statutory provisions, third-party rights (in particular personal, copyright, and trademark rights), or contractual obligations, assurances, or guarantees, including the costs of necessary legal defense (attorney and court fees at statutory rates).
3.  In the event of claims within the meaning of Section 10 (2), you are obliged to cooperate immediately and fully in clarifying the facts and to provide us with the necessary information in an appropriate manner.

11. Limitation of Liability

1. We shall be liable without limitation for all damages caused by us in cases of intent or gross negligence.
2. In cases of slight negligence, we shall be liable without limitation in the event of injury to life, body, or health.
3. Otherwise, we shall only be liable if we have breached a material contractual obligation. Material contractual obligations are those obligations whose fulfillment is essential for the proper execution of the contract and on whose compliance the user may regularly rely. In such cases, liability is limited to the compensation of foreseeable, typically occurring damages.
4. To the extent our liability is excluded or limited under the above provisions, this shall also apply to our vicarious agents.
5. Liability under the German Product Liability Act remains unaffected.

12. Final Provisions

1. The law of the Federal Republic of Germany shall apply, excluding the UN Convention on Contracts for the International Sale of Goods.
2. If you are a merchant, a legal entity under public law, or a special fund under public law, our registered office shall be the exclusive place of jurisdiction for all disputes arising from the contractual relationship.
3. Should individual provisions of these Terms of Use be or become invalid, this shall not affect the validity of the remaining provisions.

Privacy Notice

Principles of Data Processing for the Use of WLAN/Internet

To comply with the provisions of the General Data Protection Regulation (GDPR), we provide you with the following information on data protection. This fulfills our information obligations pursuant to Art. 12 et seq. and Art. 13 et seq. GDPR.

1. Who is responsible for data processing?
The controller within the meaning of data protection law is:
Partnerschaftsgesellschaft Penner + Partner mbB, Humboldtstraße 10, 40237 Düsseldorf

Further information about our company, authorized representatives, and contact options can be found in the legal notice on our website: https://pennerundpartner.de/en/impressum/

2. What data do we process? And for what purposes?

If we have received data from you, we will generally process it only for the purposes for which it was collected.
No content analysis of data transmitted via the WLAN (e.g., visited websites) takes place.
When using our WLAN, we process the following personal data for the stated purposes:

(1) Connection data for internet access, including:

• IP address
• MAC address
• Date/time
• Hostname

(2) Logs are used exclusively for:

• analysis and correction of technical errors
• ensuring system security
• network optimization
• statistical determination of total usage volume
• evaluations (misuse control)

Processing for other purposes will only take place if the necessary legal requirements under Art. 6 (4) GDPR are met. Any information obligations pursuant to Art. 13 (3) and Art. 14 (4) GDPR will of course be observed.
On what legal basis is this processing carried out?
The legal basis for processing personal data is generally—unless more specific legal provisions apply—Art. 6 (1) lit. a GDPR (consent). If personal data is processed on the basis of your consent, you have the right to withdraw your consent at any time with effect for the future.
We also store your data based on a balancing of interests (Art. 6 (1) lit. f GDPR), particularly with regard to storage duration. If we process data on this basis, you have the right, subject to the requirements of Art. 21 GDPR, to object to the processing of your personal data.

3. How long is the data stored?
We process the data for as long as necessary for the respective purpose.
Log files are generally stored for up to 3 months. Longer storage and processing are only possible if there is a legitimate interest of the controller, e.g., for evidentiary purposes.

4. To which recipients are the data disclosed?
Your personal data will generally only be disclosed to third parties if this is necessary for the performance of the contract, if disclosure is permissible based on a balancing of interests pursuant to Art. 6 (1) lit. f GDPR, if we are legally obliged to do so, or if you have given your consent.
No transfer to third countries takes place.
Data may be disclosed to authorities and/or lawyers/courts if this serves the detection of criminal offenses or if we are obliged to do so.

5. Where are the data processed?
Your personal data are processed exclusively on IT systems located in the Federal Republic of Germany.
If, in individual cases, services outside the EU are used, this will only take place on the basis of an adequacy decision or appropriate safeguards pursuant to Art. 44 et seq. GDPR.

6. Your rights as a “data subject”
You have the right to obtain information about the personal data we process about you.
For requests not made in writing, we may require proof of identity.
You also have the right to rectification, erasure, or restriction of processing where legally applicable.
You also have the right to object to processing and the right to data portability.
In particular, you have the right to object pursuant to Art. 21 (1) and (2) GDPR to processing of your data for direct marketing purposes where based on legitimate interests.

7. Our Data Protection Officer
We have appointed a Data Protection Officer:
bits + bytes it-solutions GmbH & Co. KG
Email: datenschutz@bits-bytes.de, Tel: 0700 / 20 30 10 30
Further contact details can be found at: https://bits-bytes.de/impressum

8. Right to lodge a complaint
You have the right to lodge a complaint with a data protection supervisory authority regarding our processing of your personal data. A list of supervisory authorities and their addresses can be found at:
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

Status: March 12, 2026